The complexity of the services we offer cannot be compared to larger academic teaching hospitals or even to community general hospitals. We would expect that an inspection of larger more complex facilities would also require more inspectors and a more lengthy inspection process. Smaller, less complex hospitals should be charged a much lower fee.

The proposed fee will divert funds from patient care and patient safety.

In an environment where hospital funding is being held at zero or reduced, the new fee is not affordable and would necessitate the diversion of resources from patient care to pay for this new regulatory overhead. Further the new fee may impair the ability of organizations such as ours to implement new safety measures that require new investments.

The proposed fee is exorbitant when compared to the fees charged to community pharmacies.

The proposed fees for hospitals include a $3,000 application fee, plus $3,000 issuance fee, plus an annual renewal fee of $5,000 which are exorbitant when compared to the community pharmacy fees with an application fee currently of $250 (proposed $500) and annual renewal fees currently of $860 (proposed $940).